In re Adobe Data Tracking Litigation

District Court, N.D. California·Decided September 2, 2026·No. 5:25-cv-03032·Unknown

Opinion

IN RE ADOBE DATA TRACKING Case No. 25-cv-03032-NW LITIGATION ORDER GRANTING MOTION TO DISMISS CONSOLIDATED AMENDED CLASS ACTION COMPLAINT; ORDER GRANTING MOTION TO STAY DISCOVERY Re: ECF Nos. 84, 105

Plaintiffs Nicholas Rapak, Bianca Johnston, Minchul Paul Chwe, Dana Olita, and David Concepcion bring this putative class action against Defendant Adobe Inc., alleging that Adobe unlawfully collects their data and invades their privacy while Plaintiffs browse websites that utilize Adobe’s Experience Cloud Identity Service. Adobe now moves to dismiss the first consolidated amended class action complaint (“FAC”) for failure to state a claim. ECF No. 84. The motion is fully briefed. ECF Nos. 93, 95. For the reasons set forth below, the Court GRANTS the motion with leave to amend. I. BACKGROUND1 Adobe is a software company perhaps best known for its Adobe Acrobat and Photoshop products. Adobe developed the Experience Cloud Identity Service,2 which includes unique,

1 The factual background is drawn from Plaintiffs’ FAC. See ECF No. 78.

2 Plaintiffs do not provide details about Experience Cloud Identity Service. The Court understands it to be a suite of Adobe products, but does not have more information. See FAC ¶ 39 (“Adobe expanded this project by developing the Adobe Experience Cloud Identity Service, which introduced the Adobe Experience Cloud ID or ECID, also known as ‘MID.’ The ECID is a persistent, unique identifier Adobe assigns to each user that enables tracking across Experience persistent identifiers for Adobe users called an Adobe Experience Cloud ID (“ECID”). The ECID is an identifier assigned to each user that enables tracking across Experience Cloud Identity Service products and identity syncing with third-party advertising partners. Id. Plaintiffs allege that Adobe tracks users’ data via their ECID across Experience Cloud Identity Service products and third-party partners’ websites to sell targeted ads. Plaintiffs have been impacted by Adobe’s ECID tracking; “Plaintiffs have visited popular websites and communicated sensitive information with no inkling that Adobe was watching, tracking, and collecting their data across websites and mobile applications and creating highly detailed profiles containing their most sensitive information.” FAC ¶ 8. For example, Plaintiff Rapak visited several websites that incorporate Adobe’s tracking tools. He visited Marriott Bonvoy’s website,3 “which incorporates a host of services encompassed in the Experience Cloud Platform.” Id. ¶ 94. “Without Plaintiff Rapak’s knowledge or consent, Adobe’s tracking technology caused his browser to send detailed information regarding the content of his communications with the Marriott website, revealing personal tastes and preferences.” Id. ¶ 97. Plaintiff Rapak asserts that he would not have used Marriott’s or similarly situated websites (or would have demanded payment for his data), had he known that Adobe was gathering information about him. Plaintiffs contend that Adobe’s tracking and profiling of users is ongoing. Plaintiffs bring nine claims: (1) Violation of Common Law Invasion of Privacy (Intrusion Upon Seclusion); (2) Violation of Article I, Section 1 of the California Constitution (Invasion of Privacy); (3) Violation of the California Invasion of Privacy Act (“CIPA”), Cal. Pen. Code § 631; (4) Violation of CIPA, Cal. Pen. Code § 632; (5) Violation of CIPA, Cal. Pen. Code §§ 638.50, 638.51; (6) Violation of the Comprehensive Computer Data Access and Fraud Act (“CDAFA”), Cal. Pen. Code § 502; (7) Violations of the California Unfair Competition Law (“UCL”), Cal. Bus. & Prof. Code §§ 17200 et seq.; (8) Unjust Enrichment; and (9) Injunctive Relief. FAC ¶¶ 185–281. Under Federal Rule of Civil Procedure 12(b)(6), a district court must dismiss a complaint if it fails to state a claim upon which relief can be granted. To survive a Rule 12(b)(6) motion to dismiss, the plaintiff must allege “enough facts to state a claim to relief that is plausible on its face.” Bell Atl. Corp. v. Twombly, 550 U.S. 544, 570 (2007). This “facial plausibility” standard requires the plaintiff to allege facts that add up to “more than a sheer possibility that a defendant has acted unlawfully.” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009). While courts do not require “heightened fact pleading of specifics,” a plaintiff must allege facts sufficient to “raise a right to relief above the speculative level.” Twombly, 550 U.S. at 555, 570. In deciding whether a plaintiff has stated a claim upon which relief can be granted, the court must assume that the plaintiff’s allegations are true and must draw all reasonable inferences in the plaintiff’s favor. See Usher v. City of Los Angeles, 828 F.2d 556, 561 (9th Cir. 1987). But the court is not required to accept as true “allegations that are merely conclusory, unwarranted deductions of fact, or unreasonable inferences.” In re Gilead Scis. Sec. Litig., 536 F.3d 1049, 1055 (9th Cir. 2008). A. Privacy-Related Claims (First through Sixth Claims) Consent is an element of Plaintiffs’ CIPA claim and a total defense to Plaintiffs’ common law invasion of privacy, California Constitution, and CDAFA claims. See Smith v. Facebook, Inc., 262 F. Supp. 3d 943, 955 (N.D. Cal. 2017), aff’d, 745 F. App’x 8 (9th Cir. 2018) (user consent is a defense under privacy protections under the California Constitution as well as common-law tort claims for intrusion upon seclusion); Opperman v. Path, Inc., 205 F. Supp. 3d 1064, 1072 (N.D. Cal. 2016) (user consent is a defense under CIPA); Cal. Civ. Code § 3515 (“A person who consents to an act is not wronged by it.”); Greenley v. Kochava, Inc., 684 F. Supp. 3d 1024, 1048 (S.D. Cal. 2023) (“To establish consent under CDAFA, a defendant must ‘explicitly notify users of the practice at issue.’”). Where, as here, consent is an element of at least one claim, “[c]onsideration of consent is appropriate on a motion to dismiss.” Silver v. Stripe Inc., No. 4:20- Holdings, Inc., 78 F. Supp. 3d 1125, 1136 (N.D. Cal. 2015) (“[d]efendants may properly challenge [p]laintiffs’s allegations regarding lack of consent through the instant motion to dismiss”); Smith v. Facebook, Inc., 745 F. App’x 8 (9th Cir. 2018) (affirming motion to dismiss based on plaintiffs’ consent to data tracking and collection practices). Plaintiffs contend the following allegations sufficiently plead lack of consent: • “Without [each named] Plaintiff[’s] knowledge or consent, Adobe’s tracking technology caused [his or her] browser to send detailed information regarding the content of his communications with the . . . website, revealing personal tastes and preferences.” FAC ¶¶ 97, 106, 112, 125. • “Plaintiffs and Class Members did not consent to, authorize, or understand Adobe’s interception or use of their private data.” Id. ¶ 191. ECF No. 93 at 3. Plaintiffs also point to allegations “that Adobe surreptitiously interc

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